of the conduct. it was an american who piloted the french fleet 60 miles from the iles de los tothesierraleoneriver.and that was -- if you read grammatically, we think that is what attorney general bradford was referring to. >> but -- >> ms. sullivan, before your time runs out, i mean, you have said, candidly, that if filartiga were to come up today, if marcos were to come up to this forum, there would be no basis under the alien tort statute. but assume for the moment that those two cases -- that we accept them -- to accept them. is there anything different about your case? >> yes, your honor. there are many -- many differences between us and filartiga. for one, this is a case in which there is a class action against a corporation. and if you don't agree with us on the lack of extraterritorial application, we still maintain that the ats does not apply to corporations. second, there is -- there was a -- there's an allegation here of aiding and abetting a foreign government. it was unclear in filartiga whether the paraguayan was acting within or without the state's authority, but -- and he wa

citizens were aiding the french in an attack ofthesierraleoncolony,which was a british territory. the idea that the statute could never be used extra territoryly was an extreme position. and i think the idea that corporations can never be sued, that you can signal out that category of defendants, that they can never be sued is also an extreme position they don't think is well supported. and i think the other thing that shell and -- at least sun of mecki did was take a position about the principle of international law. one of the principles of international law is that states have the right to act unless there's something that prevents them from acting. the question is do states, meaning governments, countries, do they have the ability to enforce international human rights law in various ways? can they do that by implementing principles of universal jurisdictioning where, if tortures appear on your shores, whether within your territory or whether the torture is one of your nationals, can those governments take action in support of the entire international community so that we can